S. 10 (23C):Educational institution-Application for exemption was made before wrong authority- Authority concerned should have forwarded to the correct authority instead of rejecting the said application after enquiries . [ S. 10(23C) (iv) ]
S. 10 (23C):Educational institution-Application for exemption was made before wrong authority- Authority concerned should have forwarded to the correct authority instead of rejecting the said application after enquiries . [ S. 10(23C) (iv) ]
S. 10(10B) : Compensation – Workman – De facto termination of employment on payment of agreed compensation — Eligible for exemption –Quantum to be examined by the AO .
S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services –Payments made towards allocation of expenses cannot be treated as fees for technical services – DTAA-India – France [ Art . 13 ]
DCIT v. KPMG Advisory Services (P.) Ltd. (2018) 168 ITD 34 (Mum) (Trib
S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Payment of SAP charges made to Associated enterprise for use of licensed software was liable to tax as royalty in India and liable to deduct tax at source- DTAA-India -Germany [S. 195, 201(1), 201(IA), Art 12 ].
S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Professional charges paid by assessee to a non-resident company located in Bangladesh could not be brought to tax in India as royalty – DTAA- India – Bangladesh [ Art 13(2) ]
S. 9(1)(vi):Income deemed to accrue or arise in India – Royalty – Domain name is an intangible asset which is similar to trademark. Consequently, income from services rendered in connection with such domain name registration is assessable as “royalty”-DTAA- India -USA [ S. 115A, Art .12 ]
S. 9(1)(v) : Income deemed to accrue or arise in India – Interest -DTAA would apply only when recipient of interest was not having a permanent establishment in country where it had received interest- DTAA- India –France [ Art. 12 ]
S. 9(1)(i):Income deemed to accrue or arise in India – Business connection -Technical and equipment and services for events –DTAA- India – Belgium- Portugal [ S.9(1)(vii), 90, 195,Art, 7, 12 ]
S. 9(1)(i):Income deemed to accrue or arise in India – Business connection – Title in equipment imported transferred outside India — Delivery of equipment outside India and consideration for supply of plant and equipment paid in Euros to Bank outside India – Not liable to deduct tax at source .[S.195 ]
S. 9(1)(i):Income deemed to accrue or arise in India – Business connection – Shipping, Inland waterways transport – Matter remanded -DTAA- India – Singapore [ Art ,8,24 ]